The IRS has provided important transition relief for many 403(b) plans struggling with an apparent change in IRS positions on a critical issue: how should 403(b) plans treat part-time employees who sometimes work more than 20 hours a week and sometimes work fewer? Recently issued Notice 2018-95 clarifies that what the IRS is calling “the […]

On September 28, 2018, the IRS issued Revenue Procedure 2018-52, the latest version of the Employee Plans Compliance Resolution System (“EPCRS”), the IRS’s comprehensive procedures for correcting retirement plan errors. Using this procedure, retirement plan sponsors may fix mistakes in their qualified plans, 403(b) plans, 403(a) retirement annuities, SEPs, and SIMPLEs. Although they are not […]

We are accustomed to change in this industry, but things seem to be moving quite quickly on several fronts. In this issue of the FlashPoint, we will bring you up to date as to where we stand on the Department of Labor’s (DOL) fiduciary rule changes, and also clarify the IRS’s new policy on hardship […]

The IRS just released the cost of living adjustments for various retirement plan limitations that will take effect on January 1, 2017. Most of the limits will not be increasing for 2017. The Consumer Price Index, on which these limits are based, went up on 3% during 2016. However, there were some limits that increased […]

The IRS issued Revenue Procedure 2016-37 (the “Procedure”) at the end of June, which significantly affects individually designed plans (“IDPs”) and has some ramifications for pre approved documents, such as prototypes and volume submitter documents.

Thank you for your patience in awaiting this second part to our review of the new Fiduciary rules issued by the Department of Labor. This installment will look at the potential for self-dealing if you are an advice fiduciary, and how the Best Interest Contract Exemption (BICE) can help. As with Part I, our goal […]

Understanding that there may be some situations in which the looming April 30 restatement deadline cannot be met by some adopters of defined contribution pre-approved plan documents, the IRS got the jump on providing practitioners with assistance for resolving these nonamender problems. Nonamenders: Big Trouble! A failure to restate the plan on a timely basis […]

Okay, here is the FBLC take on the new DOL fiduciary regulations. As in the past with prior proposals, we have broken our response into different parts. Today’s information will look to give just some broad rules and structure of the Regulation, itself, which defines what makes someone an advice fiduciary and what that means. […]